Principles governing our business practices

Product quality and safety

The high quality of products is a non-negotiable value for Hellenic Dairies. We make every effort to offer our clients products of excellent quality and safety.

In order to ensure the high quality of products, the company has three main tools: the specialized knowledge of its scientists, the advanced technology of its facilities, as well as the modern systems for monitoring the processes at all stages of the production process and in all facilities. At the same time, the company, in order to ensure the production of excellent quality products, has specified basic procedures and controls from the collection of raw material to the disposal of the product to the final consumer. Meanwhile, it seeks to continuously improve the processes it follows, ensuring general requirements of high hygiene everywhere in relation to all its premises. Responsibility for following the methodology in terms of recognizing, assessing and controlling food safety risks lies with the Food Safety Team, which, taking into account new scientific data, is committed to meeting the requirements of legislation and competent authorities and of course clients. For this reason, all employees involved in any way in quality assurance, research and development, as well as the preparation and packaging of our products, should: • know exactly the quality standards and procedures applicable to the products we produce; • follow all relevant control protocols; • comply with all applicable laws and regulations on food safety and environmental protection.

Should you notice anything that might adversely affect the quality of our product, please contact the Head of the Food Safety Team, indicating your concerns.

Contact us for products

We are proud of the high quality of the products we offer to the consumer and ensure proper and honest communication regarding their characteristics.

Apart from meeting internal quality standards, our products must be produced, tested, packaged and labeled in full compliance with the applicable laws. The information labeled on the packaging of our products should be the same so that it is not misleading or incorrect. Proper communication is an important aspect of the company’s responsibility and influences the corporate image. For this reason, all our labels and our advertising are designed on the basis of national and EU provisions, while respecting strict ethical standards, in order to present a balanced version of the products, without exaggeration, misleading information or false statements. In addition, the company has a telephone line for clients’ and final consumers’ service, which is indicated on the labels of its products.

Selection of partners

We work with our partners towards achieving the goals that we set as a company, also ensuring the good reputation of Hellenic Dairies in the industry.

For this reason we ask everyone who cooperates with us (suppliers, service providers, etc.) to respect our Code of Conduct, as well as the laws and regulations by which our operation is governed. We require all our partners, without exception, to be updated, accept and sign all the terms of the Code we have drafted, before starting any cooperation with them. Furthermore, Hellenic Dairies has adopted strict selection criteria for suppliers to ensure the provision of high-quality products and services, in order to always be in line with its own commitments for top quality products. Thus, in addition to the criteria relating to quality which are non-negotiable, the company has established criteria relating both to environmental performance and to the social face of its partners. Therefore, if we notice requests for advance payments that do not comply with signed contractual obligations, additional commissions, concealment of critical information, unusual transfers of money from countries with which we do not collaborate, we should highlight the matter by bringing it to the attention of the Internal Auditor or the Legal Department, reporting any immoral or inappropriate behavior or activity that comes to our attention.

Fair competition

We respect our competitors and fully implement the applicable competition legislation, always acting responsibly.

Antitrust rules and laws are complex and numerous and their application may depend on various factors. It is better to be careful and ask questions rather than assuming that an action will be acceptable - bad judgment is not an excuse.

Hellenic Dairies, recognizing that free competition is a key element of the market as it promotes economic growth, efficiency and innovation, focuses on overcoming its competitors on legal and ethical grounds. Therefore, any uncompetitive practices are not compatible with our principles, laws and values, and may prove to be precarious regarding the image we want to preserve as a company. In addition, they may lead to sanctions that may harm Hellenic Dairies such as fines, civil liability for damage, exclusion from public procurement or even criminal prosecution. In general, information on pricing, clients, partners and competitors and any other relevant information (including third party copyrights such as know-how, patents) must be communicated/received only by legal means. Our behavior should also receive similar attention, as any defamatory statement against a competitor, defamation of their products or damage to their reputation is expressly prohibited.

However, because there are many types of behavior that may be subject to antitrust laws, you must comply with these laws and if you have any questions or concerns, you should seek guidance from the legal department of the company.

Conflict of interest

We are all required to make business decisions based on the interest of Hellenic Dairies and not based on our personal interests.

A conflict of interest may arise when our personal interests affect or may be perceived as interfering with our ability to perform our work effectively and impartially. A conflict of interest may arise, inter alia, from secondary employment or equity participation of a competitor or business partner. We are not allowed to engage in any secondary employment which is contrary to the interests of Hellenic Dairies, especially if the employment in question is competitive with its activities. Business decisions concerning Hellenic Dairies should be made in a transparent manner, free of personal interests. Therefore, it is necessary to avoid any relationship or activity that could compromise, or even appear to affect, our ability to make objective and fair decisions when carrying out business activities on behalf of Hellenic Dairies. Such relationships include blood or marriage ties, cooperation with third parties or investments. Where such relationships or activities cannot be prevented or avoided, they should be directly reported. In addition, you should report to the manager any personal interest that might be perceived as related to the performance of your professional duties. In case of doubt, informing the manager is in your interest, as such an act often removes any suspicion of inappropriate activity.

Gifts, hospitality and entertainment

We always act according to the highest ethical standards. Hellenic Dairies does not offer nor accept gifts, hospitality and entertainment that may raise concerns about our integrity.

Hellenic Dairies considers that corruption and bribery are bad practices, which can be detrimental to both the interests of the company and society in general. Having the possibility of healthy development in the societies in which we operate as our fundamental task, we deplore any incident that may be perceived as an act of corrupt behavior. Adhering to laws and setting an example for doing our business in an ethical manner is a way to implement this commitment in practice. Good business relationships are based on trust and goodwill and because we value and respect our clients and business partners, a party may want to recognize this by offering gifts and hospitality. However, note that when you offer or accept gifts, hospitality and entertainment in interactions with business partners, this can lead to a conflict of interest and be perceived as bribery or inappropriate advantage. In particular, the acceptance of gifts and tips (in any place, form or value) from clients, suppliers or external partners is prohibited, unless there is prior specific permission by the competent Head of the department. Also, the acceptance of personal invitations by partners or prospective partners of the company requires prior approval.

Question: When negotiating prices with one of our suppliers, he offered me a ticket to a football match that I would really like to watch. Is it acceptable to accept the ticket? Answer: No. Employees of Hellenic Dairies are not allowed to accept gifts or entertainment from any person or company during their participation in business negotiations, tender procedures and similar procedures. You should thank your supplier, but explain why you cannot accept his offer.

Book and record keeping

We keep up-to-date accounting books and accurate records of our business transactions which enable us to trace our activities. In all our transactions and in every form of communication we are accurate and sincere.

This is the basis for how we deal with each other and what is expected from us in all our relationships with our clients, employees, investors and business partners, as well as with the public and all state agencies. No falsification or inappropriate alteration of documents and records is allowed.

The timely, complete and honest recording of financial and non-financial information and the proper preservation of our documents and records is essential for our company and is important for the following matters concerning us: • Reliability and reputation; • Legal and regulatory obligations; • The possibility of accurate forecasting and business decision-making; and • Responsibility towards shareholders and other external stakeholders.

Accurate business documents are necessary for the management of a successful company and are required by law. Each employee is responsible for ensuring that all company records, information and accounts are clear, honest and accurate. For example, expenditure reports, time records, payments and other transactions should, without exception, be correctly recorded (in a timely and comprehensible manner), accounted for and approved. For any transaction of value with a company, entity or person outside Hellenic Dairies, there should be a correct entry indicating the purpose, nature and participants in the transaction. Recordings which are incorrect, incomplete or modified do not reflect the true nature of the transactions, which is considered a fraud and is not acceptable by the company. If you have any questions about the company’s financial audits, accounting, financial reporting or audit, please contact the relevant department for clarifications.